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Introduction
The commitment of the San Luis Obispo Chamber of Commerce to securing new
water sources is one of our organization's most important legacies. In 1989, the
Chamber.Board agreed that the single most important issue facing local businesses
was that of water. This goal continues to hold true today.
The future of San Luis Obispo's water supply is uncertain. San Luis Obispo is a
coastal desert, subject to cyclical droughts. The possibility of drought conditions in
the future is a near certainty. One of the most significant hurdles to continued
economic development in our community is that additional water is still unavailable
for expansion.
The Chamber's Water Task Force was established in 1990 to identify water sources
having the greatest long term promise for the community.The Task Force published
the first comprehensive study on water by the Chamber in 1990 which was used for
several years to educate the public on water supply issues.
In 1995, the Chamber completely updated and revised this document to
accommodate new issues surrounding the water supply problem in San Luis Obispo,
as well as to incorporate changes in technology and the political climate that have
affected the feasibility of different water programs.
The Chamber continues to believe that securing an adequate water supply is the
most important challenge faced by the City of San Luis Obispo and has updated this
document once again to reflect this concern. The Chamber is committed to its goal
of providing San Luis Obispo with inexpensive, environmentally sound and'
politically feasible sources of water..
Process
In this document,the Chamber has focused on the identification of stable,long-term
water sources. Short-term emergency measures, while important in drought
conditions, accomplish little for the long-term economic health of our area.
To that end, the Water Task Force has identified potential long-term water supply
sources for the area and has analyzed each of these options based on their cost of
service delivery, reliability, environmental impact and political feasibility. The
complex interplay of each of these factors has painted a picture with several water
supply options available to the City, each with its own strengths and weaknesses.
Page 1
i
Current Situation
Drought. This is one of the most important issues affecting how San Luis Obispo
will plan for its long term water needs. In the winter months of 1995, the City saw
major flooding as a decade-long drought broke with the crash ofthunder. For many
citizens, the rains seemed to herald an end to their water supply concerns.
A longer view of the 1994-95 rainy season paints a different picture, however.
Much of the rain washed out to sea and was never used or saved. Additionally, the
season's rains did not solve the problems of groundwater contamination.
Unfortunately, groundwater contamination limits the use of our underground water
basin as a means for coping with future droughts.
Another drought will occur. It may be that next year will see a return to drought
conditions, or maybe the next drought will take longer to arrive. Nevertheless,San
Luis Obispo exists in a semi-arid climate, and our days of water abundance are
clearly over. When the next drought occurs, it is important that our community be
well-prepared. San Luis Obispo was ill-prepared for the last drought.
For three decades,water has been used as a growth control measure by many in San
Luis Obispo. This has resulted in limited access to water; when the last drought
arrived, even existing residents were left without sufficient water supplies.Limiting
water however, has not limited population growth.. Although our water supply
options have remained limited, San Luis Obispo's population has increased. Not
only have there been modest amounts of new residential development; but in
countless instances the density per housing unit has dramatically increased. The
increased density causes further strain on our existing water supply.
San Luis Obispo has a blueprint for its growth and development, our City's General
Plan. The goals, objectives, policies and programs of the General Plan reflect a
community consensus about what our City is and what it wants to become. The
City's General Plan identifies the Airport Area, Margarita Area, Dalidio Area, and
Froom Areas as future growth zones. Currently there is insufficient water to service
these areas. The importance of the airport area, in particular,to the economic and
environmental health of this community is explored in detail in the Chamber's
AirportAreaAnnexaiion:Today'sActionforTomorrow's Options. Today,because
there is very limited water for business expansion,there is a de facto moratorium on
development in the City.
Without a water supply for future expansion areas, this moratorium will continue.
If the City desires to implement its General Plan,it will.need to provide a water
supply for these growth areas. Otherwise, development will cease to occur within
City limits and will proceed on those County lands identified as greenbelt and open
space zones.
Page 2
The City of San Luis Obispo can provide a water supply, keeping development in
desirable areas consistent with the General Plan; or it can fail to provide such a
supply and allow development to occur in the County. To some extent, the lack of
a reliable water supply has already encouraged this second option to occur. Water
resources for the airport area are currently being pursued with County Service Area
(CSA)22 funding. If the City of San Luis Obispo does not want to see a separate
urban area developing on its southern border, with its own resource and
infrastructure provisions, the City will need to develop water options for this area.
The water supply question affects every aspect of our quality of life in San Luis
Obispo..Lack of water means businesses cannot expand in the City. Inevitably they
will be forced to expand into the County and the City's greenbelt areas or out ofthe
community entirely, forcing the City to bear the costs of this loss. Lack of water
means an uncertain business climate,because businesses cannot be sure that they win
be able to provide service during drought years. Lack of water for agriculture
encourages land fracturing and drives out our family farms.Lack of water means no
landscaping for residents, lowered property values and diminishing the aesthetic
beauty of our city.
Reliable, long term sources of water are vital to the health of our community,.
and the ability to maintain our quality of life
Recommendations
The good news for San Luis Obispo is that several options together can provide an
adequate water supply for our community. It is not too late to secure these options,
although further delays will result in increased costs to the community as the least
expensive options disappear.
To support the adopted City buildout identified in the General Plan,San Luis Obispo
must acquire water sources that will provide 3,861 acre feet of water per year. Of
this amount,2,500 acre feet will serve existing residents as a reliability and siltation
reserve, and 1,361 acre feet will be the additional water required for the General
Plan implementation. Water supplies must be able to deliver this much additional
water even during prolonged drought conditions, a factor known as safe annual
yield.
The Water Task.Force's analysis of the options available to San.Luis Obispo has
yielded three recommendations for water supply sources that we feel should be
pursued immediately and simultaneously. These are the Water Reuse Project, the
Salinas Dam Fxpa=on4 and the Nacimiento Project.There are also five additional
Page 3
sources that we feel are important options for the future should attempts to secure
these fail. The alternate and future sources form aseparate section at the end of this
document,and should not be dismissed.Any one could be integrated into the City's
water planning at anytime.
Water Reuse
Supply Potential: 1,233 acre feet per year
Delivered Cost Range: $716-$751 per acre foot
The City's proposed Water Reuse program centers around the concept of using
water currently processed in the City's wastewater treatment plant and discharged
to San Luis Creek. Although this water is non-potable (i.e. it cannot be consumed
by people), it.is clean and can be used to support irrigation and industrial uses.
By using reclaimed water for irrigation and industrial uses,the potable water supply
that residents and industries currently use would be freed up for other uses.
Effectively, the Water Reuse Program would increase the water supply for the City
by 1,233 acre feet per year.
Advantages of the Water Reuse Program include its environmental friendliness,
since it would essentially recycle water that has already been used. The project is
also highly reliable because drought conditions would.have little effect on this water
supply. The project will automatically grow with the City as well; when San Luis
Obispo grows to its General Plan buildout population of 56,000, the additional
residents would increase the water available through this program to 1,600 acre feet
per year.
Unfortunately,due to various regulations imposed by state and federal government,
the future of the City's water reuse program is murky. Water from the reuse
program originates from the Salinas and Whale Rock Reservoirs,but is considered
an important component of the flow of the San Luis Obispo Creek Basin by the
California Department ofFish and Game.The creek alone,without sewer treatment
plant outflow, is not drought proof, and in some dry seasons has ceased to flow.
Because of the listing of steelhead trout as a threatened species, under the
Endangered Species Act,the mitigation measures previously planned to protect this
species may be revised as negotiations with the federal regulatory agencies proceed.
Another political obstacle with this project might lie with downstream property
owners who have used the creek water for many years. Because reuse water does
not originate in the creek,downstream users do not currently possess legal rights to
it, and these users may be required to reduce their water consumption from the
creek to ensure that habitats for threatened species are sufficiently protected. If this
project is delayed,however,continued use ofthis water by downstream users could
Page 4
develop prescriptive rights and preclude the City from being able to use it in the
future.
The Chamber strongly supports the Water Reuse program. It is one of the most
cost-effective water supply options currently available, has few environmental
impacts,is politically feasible, and water rights have already been established by the
State Water Resources Control Board,.Also,thisprogram could be brought on-line
fairly quickly (within five years.)Nevertheless, water reuse alone is insufficient to
provide all of the water that the City needs, and changes to the status of steelhead
trout to "threatened," make it imperative to pursue this in conjunction with other
projects.
Salinas Reservoir Expansion
.Supply Potential: 1650 acre feet per year
Delivered Cost: $700- 1000 per acre foot
The Salinas Dam was constructed as a project to supply water for Camp San Luis
Obispo and the City during World War 11. It was constructed by, and is owned by,
the Army Corps of Engineers. Itis presently managed by the County Flood Control
District. It is currently used for water only by the City of San Luis Obispo. The
original construction called for inclusion of an operable gate on the dam spillway.
In 1941, the Army decided the gate was not needed and it was never installed.
The Salinas Reservoir Expansion Project would complete the original plan for the
dam by constructing the gate, resulting in an additional safe annual yield from the
reservoir of 1,650 acre feet per year. The Army Corps has indicated that they will
not allow construction to proceed until ownership of the dam facilities and
surrounding property are transferred to a local agency. The agency to acquire
ownership will most.likely be the County Flood Control.and Water Conservation
District.
Prior concerns over the seismic safety of the dam have turned out to be unfounded,
but as the project has continued, several issues have been raised regarding the draft
environmental impact report. The City of San Luis Obispo implemented a phased
approach to the project, and has committed to include mitigation measures that will
alleviate environmental impacts that the project may create,including mitigating for
the loss of oak trees and wetlands that will be inundated as the water level rises.
Additional costs associated with the environmental mitigation process and increases
in construction costs have resulted in the cost per acre foot-ofwater increasing from
original estimates of$3 00.Nevertheless,water from the Salinas Dam still represents
the most cost-effective source of additional water for the City. If the City chooses
not to proceed with the expansion, however,it may sacrifice its right to pursue the
Page 5
expansion at a later time, because the State may reduce the City's storage right at
the reservoir.
A stumbling block to obtaining additional Salinas water is political pressure,
primarily from the North County; against the project. Several individuals and
agencies have threatened to take legal action protesting the project if the City
proceeds with its current plan. Although the case law suggests that the City would
prevail in such legal action, litigation would slow the completion of the project and
increase the cost for delivering the water.
The Chamber strongly supports continued pursuit of the. Salinas Reservoir
expansion, with continued mediation and arbitration to resolve issues of merit.
Additional Salinas Reservoir water is likely to remain one of the most cost-effective
solutions to San Luis Obispo's water shortage. Although there is some opposition,
the proposed alternative to Salinas Reservoir water, the Nacimiento Water Supply
Project, could.be halted at any time if one of the four major players withdraws from
the project. The Chamber feels that the City of San Luis Obispo should not sacrifice
its water rights at the Salinas Reservoir solely to pursue the Nacimiento project,
especially because the success of Nacimiento relies on agreements outside the City
of San Luis Obispo's control.
Nacimiento Water Project
Supply Potential: 3,380 acre feet per year
Delivery Cost: $750-$1,100 per acre foot
The Nacimiento Project is a regional project that is proposed to serve eighteen
different water agencies. The County of San Luis Obispo has an entitlement of
17,500 acre feet of water per year from Lake Nacimiento, and plans to divide that
water supply among agencies around the county. The project consists of
construction of an intake structure, pumping stations, and 66 miles of pipelines to
deliver water to the participating agencies.
Al the time of this report's publication, participating agencies have been identified
and requests for water allocations have been made. No agencies have signed a
contract obligating themselves to take their allocation.Requests from Paso Robles,
Templeton,San Luis Obispo,and Atascadero constitute the four largest requests for
water allocation in the project.
Several advantages exist to pursuing the Nacimiento project as it now stands. The
Project could provide almost all of the water needed to support existing residents
in San Luis Obispo's General Plan buildout,'and reliability studies have shown that
the lake could have provided the City with its full allocation in every year from 1950
through the present had the project existed at that time. (this includes the most
Page 6
critical year of the recent drought.)Furthermore,in some areas,there is a great deal
ofpolitical will to move forward.. The County Board of Supervisors and each ofthe
participating agencies has indicated strong support for the project.
The project may have considerable environmental impacts resulting from the
construction of 66 miles of pipeline. Although these can be mitigated, the cost of
mitigation may be higher than for other alternatives.
The continued political cooperation of the nearly twenty separate entities required
to ensure the success of this project is a significant uncertainty. If any one of the
four major players in the project chooses not to pursue its allocation, the entire
project could grind to a halt. Several North County agencies have encouraged San
Luis Obispo to participate in the Nacimiento project instead of the Salinas Dam
expansion.There is concern,however,that the Nacimiento project might fail or stall
after San Luis Obispo has given up its ability to pursue Salinas Dam water because
Paso Robles, one of the major agencies in the Nacimiento project, does not need
additional sources of water for at least a decade.
The Chamber supports the Nacimiento project largely because of the current
political will that suggests that it will likely be successful as details become more
defined.We feel that the City of San Luis Obispo should also continue to pursue the
Salinas Reservoir and Water Reuse programs because the success ofthe Nacimiento
project is far from ensured.
Other Options
Through a balanced approach to pursuing the three major projects recommended,
it is likely that the City,will reach its goal of securing a water supply source to
support the General Plan buildout requirement of 3,861 acre feet, and protecting
existing residents in times of drought. If any of these projects fail, there are other
options available that may provide a water supply for the City, although many are
less attractive than the Water Reuse Program, Salinas Reservoir Expansion, and
Nacimiento Project.
The Chamber feels that other options should be monitored closely because they
represent clear possibilities for greater efficiency in the water supply system. These
projects are listed in this section because, for the most part, they are still in the
embryonic stages. Other options represent ongoing efforts that are extremely
important to the community's water situation,but provide only limited opportunities
for development of additional water supplies.
Page 7
Conservation/Retrofitting
Supply Potentials Limited
Delivered Cost Range: Variable
Clearly, the most environmentally sensitive method for increasing the amount of
water available for use is through the conservation of existing water sources. The
City of San Luis Obispo has had an aggressive conservation program in place for
several years, which has been quite effective in reducing the amount of water used
in the city.
The hallmark of the City's program in this regard has been the toilet retrofit
program. This program has sought to replace all high water use toilets in the city
with smaller capacity toilets.
The effectiveness ofthis program is documented bythe fact that approximately 55%
of toilets in the City have already been retrofitted. Although retrofitting is not
complete, the City's water use figures have already accounted for full retrofitting,
so additional retrofitting will not provide an additional source of water.
San Luis Obispo's current planning use rate of 145 gallons per capita per day is one
of the lowest in the State. Actual usage is currently less than this figure, although
usage has risen since mandatory rationing ended. This is a testament to the
effectiveness of the City's conservation program, but also_makes significant
additional savings unlikely in the future.
From time to time, increases in technology will arise that may result in additional
opportunities for expansion ofthe City's conservation program. The Chamber feels
that where feasible,any incentive-based measures that encourage water conservation
.should be pursued. At the current time, however, the already high level of
conservation among city residents, coupled with the difficulty of encouraging
additional conservation in non-drought periods,suggests thafthese methods cannot
provide a significant new source of water.
State Water
Supply Potential: dependant upon negotiations
Delivered Cost Range: $700 - 1000 per acre foot
Based on a 1992 voter referendum rejecting state water,the San Luis Obispo City
Council directed its staffto permanently retire the prospect of using the State Water
system as a water supply source for the City. Today, new information about State
Water should allay many of the concerns opponents to it have had and make it an
attractive option.
Page 8
,I
The Chamber does not suggest that San Luis Obispo disregard the results of its
citizens' referendum. We do feel, however, that all viable water sources should be
considered by the City, and that over time, as new data surfaces, the City should
remain open to all possible water supply options, not the least of which is State
Water.
Today, State Water can be considered an accessible and safe option. There are
unique and creative ways in which state water can be utilized. Significantly, State
Water is potentially a possible source for the City's reliability reserve, a 2,000 acre
foot per year"extra" source of water to be used only in emergency conditions. The
flexibility of using state water for such a program is evidenced in that the entire
reliability reserve could be reasonably assured simply by installing a turnout in the
state water pipeline so that water could be purchased from another community if
San Luis Obispo's resources dwindle to a point of critical danger. This concept of
"wheeling" water is based on the ability of a participating community to trade or
purchase excess water from another community that also participates in the State
-Water project.
The Chamber encourages the continued analysis of State Water as a future resource
option. The use of State Water as a source for the City's reliability reserve is an
innovative use of this resource not precluded by the voter referendum.The political
disfavor surrounding the project in the past can be offset by wider dissemination of
more current information. Detractors had been concerned with safety and cost
issues. We now know that the quality of state water does not present a safety
hazard. Additionally, the higher than previously estimated costs of other water
projects, like Nacimiento and the Salinas Dam Expansion, make State Water now
seem to be an affordable and plausible alternative.
Distribution Enhancements/Regional Water Management
Supply Potential: not.available
Delivered Cost Range: not available
A major possibility for enhancing the water supply delivery system in San Luis
Obispo County exists in the concept of regional water management. Currently,each
water project has an independent delivery system which has resulted in serious
inefficiencies. As an example,there currently exists one pipeline that transfers water
from the Whale Rock Reservoir to San Luis Obispo, while a second parallel line
transfers water in the opposite direction from the State Water line to Morro Bay.
Combining the resources of the various water projects in the county and correcting
these types of inefficiencies would result in.large economies of scale resulting from
decreases in transportation costs, more effective water treatment, and an increased
ability to"trade" water between communities in difficult times.
Page 9
Recently, the County of San Luis Obispo has expressed interest in the possibility of
developing a regional water management system. The feasibility of such a system
will be greatly enhanced by pipelines that will spread across the county as
communities become connected to the Nacimiento project. The Chamber supports
continued exploration of the idea of regional water management by all of the
relevant parties in the region, even though it is too early to predict specific dollar
savings to each community at this time.
Desalination
Supply Potential: unlimited
Delivered Cost Range: $2000 +/- per acre foot
Desalination is a process by which salts and minerals are removed from seawater,
resulting in clean potable water for human use and consumption. Traditionally,
desalination has been the most expensive water source option for communities, and
has been used mainly in areas where other sources ofwater are technically infeasible
or politically impossible to develop.
In recent years desalination technology has become more affordable. In some cases
desalination has become an economically viable alternative water source.
Desalination has several advantages over conventional water sources including its
extreme reliability as a water source, low transportation costs in communities near
the ocean, and the fact that reservoirs for storing water do not need to be
constructed (the sea is the world's largest reservoir). The desalination process
removes impurities from the water, so issues of contamination that surround other
sources such as groundwater wells are not a problem with.desalinized water.
Environmental concerns that have traditionally surrounded desalination maybecome
less of a concern as new technologies develop to address these issues. Currently,the
largest environmental issue is the discharge of brine into the ocean.
San Luis Obispo County already has two intake and outfall systems for seawater,
one at the Morro Bay Power Plant and the other at the Diablo Canyon Power Plant.
Used in conjunction with regional water management strategy, desalination could
become a more economical water source because these facilities have already been
constructed.
Depending on how economies of scale can be introduced to a desalination program,
the cost per acre foot of water would range from$1500 to $2000. At the present,
other potential sources ofwater exist that could.satisfy the needs of San Luis Obispo
more economically. The Chamber feels that it is extremely important to monitor
desalination as an option,however, because continued technological advances and
the possibility of regional water management could make this process an affordable
option in the future.
Page 10
Groundwater Use
Supply Potential: limited
Delivered Cost Range: 5300 to 1000 per acre foot
San Luis Obispo has a.history of utilization of groundwater to supply its domestic
needs. From the 1920's through 1941 (with the opening of the Salinas Reservoir),
wells on the Dalidio land were one of the City's primary water sources. During the
last drought period (1988-1992), San Luis Obispo developed several wells in
addition to those on the Dalidio land to extract ground water. This was a fairly
effective emergency measure,but resulted in subsidence because the new wells drew
down the water table in an area not previously mined. The soil subsidence resulted
in significant costs to the City because of claims filed by affected property owners..
The City's current estimate of ground water production is five hundred acre feet of
safe annual yield per year. However, in addition to the four hundred acre feet of
water produced in 1995-96, agricultural uses also utilized about one thousand acre
feet of water from this groundwater source. If some of this land is urbanized (e.g.
portiops ofthe Dalidio property or the Froom Ranch),portions ofthis ground water
could be released for domestic consumption. If the water is pumped from historic
Well locations, overdrafting of the basin or further.sol subsidence may be avoided.
While some of this water may require treatment for TCPs and nitrates,there is also
the potential to mix the water with other supplies to dilute the concentrations to
acceptable levels. It is also possible that this water could be used for landscape and
other non-potable uses thereby lowering the City's overall need for new sources of
water.
The Chamber feels that the use ofgroundwater,while not providing a single solution
to the City's future water requirements, should be kept as an active option. This
water source could be utilized for either direct supply or for reserves in the case of
drought conditions as was in the drought of the early 1990's.
Page 11
Conclusion
In 1990, the City of San Luis Obispo first endorsed a multi-source water strategy,
designed not only to find solutions to the drought but to provide better reliability
and planning for the long-term water needs of the City as well. The Chamber
wholeheartedly supports this policy, which has begun to show real benefits as the
Water Reuse Project, Salinas Reservoir Expansion and Nacirriiento Project have
entered into the planning stages.
It is important that the City retain the political will that has allowed these projects
to go forward. Recent Councils have demonstrated a sincere desire to proactively
solve San Luis Obispo's water resource issues rather than returning to the decades-
old, destructive paradigm of crisis management. We hope future ones will do so as
well.
The Chamber acknowledges that securing water supply sources is one of the most
difficult political issues to face any city. All too often, the political obstacles that
surface whenever, any community seeks to supply itself with that most valuable
commodity, water, seem impossible to surmount.
The result offailing to make the difficult political decision to provide water for one's
residents and businesses, however; is all too clear in several other communities in
San Luis Obispo County as costs have soared and businesses have departed. San
Luis Obispo's General Plan seeks to avoid that situation by directing the
development of adequate water supplies for the future.
We strongly urge the City to continue pressing forward with the Water Reuse
Program, Salinas Reservoir Expansion and Nacimiento Project, and to continue
monitoring the possibility of other options, particularly State Water, as they arise.
The issue of water is, in our opinion, the most important decision this City must
make, and the Chamber most strongly supports all City efforts to ensure our
successful future with an adequate water supply.
Page 12
AGENDA
DATE / ITEM#._Mm.
1283 Woodside Drive
San Luis Obispo, CA 93401
805-594-1906
ancarter@aoLcom
6gOUNCIL ❑ CDD DIR
BT4AO ❑ FIN DIR
July 8, 2001 AAO ❑ FIRE CHIEF
ORNEY ❑ PW DIR
City Council CLERK/ORIG ❑ POLICE CHF
990 Palm Street ❑ DEPT HEADS ❑ RSGrDIR
San Luis Obispo, CA 93401 ElHRI D RIR
Dear Council Members: 74�25,AoZ
I am providing you in advance with the remarks I plan to make at your meeting on
Thursday concerning MTBE in Santa.Margarita Lake.
I have also provided additional information which might be of help should you decide to
try to get the County Supervisors to treat this health risk more seriously.
Sincerely,
Andrew Carter
RECEIVED
JUL 0 9 2001
SLO CITY COUNCIL
Remarks to City Council on MTBE in Santa Margarita Lake. 7/12/01
Andrew Carter, 1283 Woodside Drive, San Luis Obispo. .I trust that you have already received a
copy of these remarks phis additional information I provided the Clerk on Monday.
On June l0x',the County Board of Supervisors received a report from Cart Batson, County
Environmental Health Director,that MTBE has been found in Lopez Lake, Santa Margarita
Lake, and Lake Nacimiemo. Santa Margarita Lake which serves as the primary drinking water
source for the City of San Luis had the highest MTBE levels.' It is my primary concern this
evening.
The State considers MTBE to be a health risk in drinking water at 13 parts per billion,but finds a
level of 5 parts per billion renders water unpalatable due to taste and odor.2 The MTBE levels in
Santa Margarita Lake were 4.5 and 5.6 parts per billion in two recent samplings taken near the
marina. According to Ken Earing, Supervisor of the City Water Treatment Plant, no MTBE has,
as of yet,been found in the City's Santa Margarita intake water.3
The County assumes motor boats and Jet Skis are the source of MTBE in county lakes. This is
because most boats are powered by two-stroke engines which are notoriously polluting.
According to the EPA and the California Air Resources Board,two-stroke mar-me engines can
dump as much as 25%of their gasoline/oil mixture directly into the water.4 Not surprisingly, no
MTBE has been found in Whale Rock Reservoir because no boating is allowed there.s
Based on the Environmental Health Director's report,the County Supervisors have decided to
launch a public relations campaign to encourage boaters to purchase MTBE-free gasoline and to
list on the County's website the few locations where MTBE-free gasoline can be bought. No
other action was taken,not even a requirement for the Santa Margarita Lake marina to sell
MTBE-free gasohne.6
I am appalled by the County Supervisors' lackadaisical approach to this serious public health
issue. Given the incredible solubility of MTBE,what assurance do we have that it will not end
up in the City's drinking water? Absolutely none!
MTBE-free gasoline at the Santa Margarita Lake marina would obviously be a first step,but it is,
in reality,not the answer to the problem. Why? Because most boaters purchase their gasoline
elsewhere. That's why MTBE is being found in Lopez and Nacimiemo even though marinas
there sell MTBE-free gasoline.'
MTBE is to be eliminated from gasoline in California by January 18'', 2003,but MTBE isn't the
only issue. Gasoline contains many other dangerous pollutants like benzene,toluene, and
xylene. Some of these are known carcinogens.
Are any of these other polhrtants in our lakes? We don't know. According to Scott Milner at
Environmental Health,the County has not tested Santa Margarita Lake or the other lakes for
these substances. In.ihct,Mr. Milner did not know.when or ifthe County is planning to conduct
such testing.9
Andrew Carter,07/12/01 Page 1 of 6
I believe the minimum effective measure to protect Santa Margarita Lake would be to ban all
two-stroke marine engines This is the step that was taken in June 1999 on Lake Tahoe by the
Tahoe Regional Planning Agency and in January 2000 on San Pablo Reservoir by the East Bay
Municipal Utility District. In both cases, action was taken when MTBE was discovered at levels
less than that found in Santa Margarita Lake.10
I personally advocate,however,banning all motorboats on Santa Margarita Lake. We should
treat this lake the same way we do Whale Rock Reservoir.
I find it incredible that people aren't allowed to swim in Santa Margarita Lake for fear of
bacteriological contamination,yet motor boating and gasoline contamination are just fine. This
is the case even though it is easier to deal with bacteriological contamination in drinking water,
be it from humans or the cattle in the Santa Margarita Lake watershed That's why the City
treats its drinking water with ozone and chlorine."
I urge you to do what you can to get the County Supervisors to take the health risk of MTBE and
other gasoline pollutants in Santa Margarita Lake more seriously.
Thank you.
Footnotes
1) "Area Lakes Tainted by MTBE,"The Tribune, 6/20/01
2) "MTBE in California Drinking Water,"California Department of Health Services,
(www,dhs.cahwnet.gov/pstddwem/chemicaL%/MTBE/rabeindex.htm)
3) 6/20/01 Tribune article plus telephone conversation with Ken Earing,w/o 6/25/01
4) Two-stroke engines pollute the most when idling or operating at low speeds.
"Final Rule for New Gasoline Spark-Ignition Marine Engines,"Environmental Protection
Agency, 61 FR 52087 10/4/96,(www.epa.gov/docs.fedrgstr/EPA AIR/1996/October/Day-
04/pr-23721.w.html)
"Staff Report,Public Hearing to Consider Adoption of Emission Standards for Spark-
Ignition Marine Engines," State of California Air Resources Board, 10/23/98,
(www.arb.ca.gov/regact/marinelmarine.htm)
Motor boats are allowed on all three county lakes. Jet Skis are only allowed in Lopez Lake
and Lake Nacimiento.
5� 6� 7) 6/20/01 Tnbune article
Andrew Carter,07/12/01 Page 2 of 6
8) EPA and California Air Resources Board reports phis Proposition 65 List of Known
Carcinogens, State of California, Office of Environmental Health Hazard Assessment,
(http://www.oehha.ca.gov/prop65/prop65 HW62201LSTB.htm)
9) Telephone conversation with Scott Milner,w/o 6/25/01
10) The highest MTBE reading found in Lake Tahoe before enactment of the 6/99 two-stroke
engine.ban was 4.2 parts per billion. The Tahoe Regional Planning Agency conducted
exiensive testing in 1997 and 1998. Benzene,toluene, and xylene were all found in Lake
Tahoe in addition to MTBE. Source: `Environmental Assessment for the Prohibition of
Certain Two-Stroke Powered Watercraft,"Tahoe Regional Planning Agency, 1/19/99,
(www.trpa.mZBoadnghwo_stroke.html)
The highest MTBE reading found in San Pablo Reservoir before enactment of the 1/00 two-
stroke engine ban was 5.5 parts per billion. Whether testing was conducted for other
gasoline pollutants was not reported Source: "1999 Annual Water Quality Report,"East
Bay Municipal Utility District, (www.ebmud.com/pubs/annual/wtrqhyOO.pdf)and `2VITBE
in Drinking Water. Surface Water Sources,"California Department of Health Services,
(www:dhs.eahwnet.gov/pslddwem/chenucdsMME/surfacewater htm)
11) Telephone conversation with Ken Earing,w/o 6/25/01;personal knowledge based on eight
year's employment in the bottled water industry;and"City of San Luis Water Treatment
Plant"brochure.
Andrew Carter,07/12/01 Page 3 of 6
Additional Information on MTBE Pollution in Lakes and Reservoirs
MTBE represents 11%by volume of unleaded gasoline in California. It is to be removed from
California gasoline by January 1,2003. At that time, MTBE may be replaced with ethanol'
1997 testing by members of the Association of California Water Agencies found MTBE in 21 of
34 reservoirs tested at levels from 0.4 to 44 parts per billion.2
By the end of 1999,the California Department of Health Services knew of 26 surface drinking
water sources across the state that contained MTBE at levels from 0.4 to 22 parts per billion. In
addition, DHS knew of 46 underground drinking water sources contaminated by MTBE.3
Most reservoirs in California are open to motor boating. As of 7/99,however,ten had imposed
full or partial boating limits to combat MTBE contamination.4
In 1999,when the Tahoe Regional.Planning Agency permanently banned two-stroke marine
engines from Lake Tahoe, agency staff believed that two-strokes dumped up to 30%of their fuel
(gasoline and oil)into the water. Two-stroke engines dump the most fuel into the water when
idling or operating at low speeds.
After accounting for evaporation and-lesser pollution when-marine engines are operating at
higher speeds, staff estimated that 10%of the fuel initially placed in two-stroke gas tanks
remained permanently in the water. Agency studies showed that two-strokes represented less
than 13%of the total fuel usage by boats on Lake Tahoe in 1997/98,but caused 90%of the
MTBE pollution, 80%of the toluene pollution, and 70%of the benzene pollution-5
In 1993,one author estimated that two-stroke marine engines dumped the equivalent of 15
Exxon Valdez oil spills into lake and salt water in the United States each year. The Exxon
Valdez was a 10.8 million-gallon spill.6
The EPA has taken steps nationally to force manufacturers to make two-stroke marine engines
less polluting. From 1998 through 2006, it is requiring manufacturers to gradually reduce
hydrocarbon pollution in new engines. The goal is a 75%reduction by 2006 from the base year
of 1997.
No retrofitting of older engines is required,however. Due to the long life of these engines,the
EPA estimates that a total 75%reduction in pollution from all two-stroke engines in service
won't be achieved nationally until 2025.
The EPA chose not to regulate four-stroke marine engines because it found them to be 85%less
polluting than two-stroke engines.'
In 1998,the California Air Resources Board (ARB),trumped the EPA and established tougher
two-stroke standards for California. ARB decided that two-stroke marine engines sold in
California should meet the EPA's 2006 standard by 2001. ARB also set even tougher standards
Andrew Carter,07/12/01 Page 4 of 6
1
1
for 2004 and 2008. The ultimate goal is a 91%reduction in hydrocarbon pollution from the 1997
base year.
The Air Resources Board noted that a 1998100-horsepower personal watercraft operating for
seven hours dumped as much pollution into the environment as a 1998 passenger car operated
100,000 miles.
This"Summary of Technology"from the ARB staff report shows why the EPA and ARB have
both focused on two-stroke engines. It also shows that some fuel-injected four-stroke marine
engines on the market in 1998 were already meeting the ARB's final 2008 standard. (Four-
stroke engines cost more than two-stroke engines,but they achieve up to 3006 better fuel
economy.)
Typical Emissions
Technology gramsdWowatt-hour Level of Development
On the market
Carbureted two-stroke 100-600 (Most common form of outboard marine
and personal watercraft engine)
Carbureted two-stroke 50- 100 Not yet on the market,
with catalyst not developed
2001 ARB Standard 48
Direct injection two-stroke 24-45 On the market
2004 ARB Standard 38
Carbureted four.-stroke 15-35 On.the market
(Most common form of inboard
marine engine)
2008 ARB Standard 17
Direct-injection two-stroke 10- 13 Not yet on the market,
with cyst not developed
Fuel-injected four-stroke 8-25 On the market
Fuel-injected four-stroke 4- 12 Not yet on the market,but
with catalyst developed for other purposes
ARB is not requiring the retrofitting of existing engines. ARB staff estimates it will take 16
years after each implementation date before half the total two-stroke outboard engines in use will
meet that standard and 9 years after each implementation date before half the total two-stroke
personal watercraft in use will meet that standard.$
Although California generally allows motor boating on reservoirs, many other places do not. In
fact,five states have an outright statewide ban forbidding motor boating on reservoirs(Delaware,
Connecticut,Rhode Island,Vermont, and Montana). Where statewide bans do not exist,local
Andrew Carter,07/12/01 Pale 5 of 6
water authorities themselves often forbid it. This is particularly true for smaller reservoirs the
size of Santa Margarita Lake.9
An example of how seriously one municipal water authority treats all forms of pollution is the
New York City Water Supply System. New York City owns 22 lakes and reservoirs with a
watershed of almost 2000 square miles. Many of the reservoirs are bigger than Lopez Lake and
Lake Nacimiento. All the reservoirs are fenced and gated Only row boating for fishing
purposes is allowed, and all rowboats must be inspected and steam-cleaned before they are
allowed on the water. In addition,New York City has entered into a management agreement
with the EPA,the State of New York,and the various counties and municipalities in its
watershed. Pollution from all sources is regulated. This includes commercial, industrial,
agricultural, and residential pollution—both point-based and non-point based. In many
watershed communities,New York City itself has built and operates the local sewer system.io
Footnotes
1) &2) 'Me Knock Against MTBE,"Metropolitan Water District of Southern California,
(www.mwd.dst.ca.us/docs/waterqualky/mtbe/mtbe.htm)
3) "MTBE in Drinking Water. Surface Water Sources,"California Department of Health
Services, (www.dhs.cahwnet.gov/pslddwem/chemicalstAME/mdacewater.htm)
4) 7/6/99 Letter from Alan C. Lloyd, Chairman, California Air Resources Board,to M'K
Veloz of Californians United for Boating, (www.arb.ca.gov/repct/marine/marine.htm)
5) `Environmental Assessment for the Prohibition of Certain Two-Stroke Powered
Watercraft,"Tahoe Regional Planning Agency, 1/19/99, (www.trpaorg/Boating/
two_strokel tml)
6) Andre Mele,Polluting for Pleasure, Norton,New York, 1993 as quoted in "Caught in the
Wake, The Environmental and Human Health Impacts of Personal Watercraft,"Izaac
Wakon League of America, 1999,(www.rwla.org/reportstpwc.html)
7) "Final Rule for New Gasoline Spark-Ignition Marine Engines,"Environmental Protection
Agency, 61 FR 52087 10/4/96,(www.epa.gov/docs.fe4rgstr/EPA-AIR/1996/October/Day-
04)pr-23721.txt.html)
8) "Staff Report,Public Hearing to Consider Adoption of Emission Standards for Spark-
Ignition Marine Engines," State of California Air Resources Board, 10/23/98,
(www.arb.ca.gov/regact/marinq/marine.htm)
9) "Is There Gas in Your Glass?",Earth Island Journal, Fall 1998,(www.earthisland.org/
ei ournal/&1198/eia fall98bhiewater.html). Also various Earth Island"Fact Sheets,"
(www.earthisland.org/bw/)
10) `New York City Water Supply System,"New York City.Department of Environmental
Protection,(www.nyc.gov&tml/dep&tml/watersup.html)
Andrew Carter, 07/12/01 Page 6 of 6